Lanigan v. Berryhill

Record failed to support ALJ’s denial of claimant’s application for Social Security disability benefits based on claimant’s back condition, diabetes, anxiety, depression and suicidal preoccupation. While vocational expert opined that claimant could work as either hand packer, machine operator or factory inspector given ALJ’s description of claimant’s limitations, ALJ’s hypothetical failed to account for claimant’s moderate limitation in concentration, and ALJ had no substantial basis to conclude that claimant would not be off task more than 10 percent of his work time. Also, ALJ could not ignore treating physician’s records that supported claimant’s claim that he suffered black-outs and other serious difficulties in concentration. Moreover, ALJ erred in basing claimant’s ability to perform full-time work on claimant’s record of part-time work, where said part-time employer had been generously accommodating claimant’s limitations.